## Technical Support Document:

Recommended Attainment/Nonattainment Designations

in Illinois for the 2010 Revised Primary 1

- H our SO 2



## National Ambient Air Quality Standard

AQPSTR 11

- 02

June 2 , 2011

Illinois Environmental Protection Agency

Division of Air Pollution Control

1021 North Grand Avenue East

P.O. Box 19276

Springfield, IL 62794

- 9276

www.epa.state.il.us2 

### Table of Contents

TABLES

................................ ................................ ................................ ................................ ......... 3

FIGURES

................................ ................................ ................................ ................................ ....... 4

INTRODUCTION

................................ ................................ ................................ ......................... 5

FEDERAL GUIDANCE

................................ ................................ ................................ ............... 6



### F IVE 

### F ACTOR 

### A NALYSIS

................................ ................................ ................................ ............................ 7

1. A IR Q UALITY D ATA

................................ ................................ ................................ ................................ .. 7

2. E MISSIONS

- R ELATED D ATA

................................ ................................ ................................ .................... 7

3. M ETEOROLOGY

................................ ................................ ................................ ................................ .......... 7

4. G EOGRAPHY /T OPOGRAPHY

................................ ................................ ................................ .................... 7

5. J URISDICTIONAL B OUNDARIES

................................ ................................ ................................ ............... 8

ILLINOIS AIR QUALITY

................................ ................................ ................................ .......... 8

ILLINOIS 5 FACTOR AN ALYSIS

................................ ................................ .......................... 11

T AZEWE LL C OUNTY

................................ ................................ ................................ ................... 11

L A S ALLE C OUNTY

................................ ................................ ................................ .................... 1 7

C OOK AND W ILL C OUNTIES

................................ ................................ ................................ ....... 22

M ADISON C OUNTY

................................ ................................ ................................ .................... 27

RECOMMENDATIONS

................................ ................................ ................................ ............ 333 

### T ABLES

Table 1 2008

- 2010 Illinois SO 2 Design Values (ppb)

... ...... ............... ......... ... . ... . . ... .. . 9

Table 2 Peoria Area Air Quality Data for 2008

- 2010 (ppb)

... ............... ....... ... . . ...... ... 11

Table 3 Tazewell and Peoria County Reported SO 2 Emissions for 2007

- 2009 ...

... ... . . .... . 12

Table 4 La Salle County Air Quality Data for 2008

- 2010 (ppb).................

. .......... . ... . .... .. . . .. 17

Table 5 La Salle County Reported SO 2 Emissions for 2007

- 2009

... ............ ......... . . . .. . . 17

Table 6 Cook and Will County Air Quality Data for 2008

- 2010 (pp b)

............... . ... .. ... . 22

Table 7 Cook and Will County Reported SO 2 Emissions for 2007

- 2009

................ .... ... 23

Table 8 Metro

- East Area Air Quality Data for 2008

- 2010 (ppb)

......... ................... . ... 28

Table 9 Madison County Reported SO 2 Emissions for 2007

- 2009

............... ....... ... . . ... 28

Table 10 Recommended Attainment/Nonattainment Designations in Illinois f or the 2010

Revised Primary 1

- H our SO 2 National Ambient Air Quality Standard......

... ..... ... 35

Table 11 SO 2 NAA Five Factor Documentation

...... ........................ .................. . . .. 364 

### F IGURES

Figure 1 Illinois 1

- hour SO 2 Design Values 2008

- 2010

................................. . . ... 10

F igure 2 Location of Major SO 2 Emission Sources in Tazewell and Peoria Counties..

. . . 12

Figure 3 Greater Peoria Airport Climatological Wind Rose

...... ..................... ... ... . 13

Figure 4 Pekin Pollution Rose

......................................................... ............ . 14

Figure 5 Aerial Photo of the Pekin Monitor and n earby Facilities

.. ..................... . . .. . 15

Figure 6 Proposed SO 2 Nonattainment Area Boundary for Tazewell County

....... ... . . .. 16

Figure 7 Location of Major SO 2 Emission Sources in La Salle County

................ ... . . 18

Figure 8 Greater Rockford Airport Climatological Wind Rose

................. ......... . ... . 19

Figure 9 Oglesby Pollution Rose

........................ ............ ........................... . . 20

Figure 10 Aerial P hoto of the Oglesby Monitor and nearby Facility

..... .. .................. . 20

. Figure 11 Proposed SO 2 Nonattainment Area Boundary for La Salle County

.... ......... . . 21

Figure 12 Location of Major SO 2 Emission Sources in Cook and Will Counties

. . ...... . . ... 23

Figure 13 Chicago

- O’Hare Airport Climatological Wind Rose

...... ...... ................. . .. 24

Figure 14 Lemont Pollution Rose

......... .......................... ........................ ... ... . 25

Figure 15 Aerial P hot o of the Lemont M onitor and n earby Facilities

.. ... . ................ . . ... 26

. Figure 16 Proposed SO 2 Nonattainment Area Boundary for Cook and Will Counties

.... . 27

Figure 17 Location of Major SO 2 Emission Sources in Madison County

............... . ... . . 29

Figure 18 St. Louis

- Lambert Field Climatological Wind Rose

......... ........... ......... ... 30

Figure 19 South Roxana Pollution Rose

................................. ........... ............ . . . 31

Figure 20 Aerial P hoto of t he South Roxana Monitor and n earby Facility

.. .. ...... . . ... . . ... 31

Figure 21 Proposed SO 2 Nonattainment Area Boundary for Madison County

...... ... . ... . 32

Figure 22 Proposed SO 2 Nonattinment Areas

.................. .............................. . .. .. 345



### Introduction

On June 2, 2010

, the U.S. Environmental Protection Agency (U.S. EPA) revised the primary

Sulfur Dioxide ( SO 2 ) N ational Ambient Air Quality Standard (NAAQS) in response to current

scientific evidence which link s short

- term exposure to SO 2 with adverse health effects in

humans

. U

. S

. EPA health studies show that short

- term e xposure to SO 2 , ranging from 5

-

minutes to 24

- hours

, result s in adverse respiratory effects and increased asthma symptoms,

particularly in children, the elderly

, and asthmatic s

. According to U.S EPA

, there is currently

little evidence suggesting a relationship between long

- term exposure to SO 2 and health effects.

As a result, U.S. EPA revoked both the previous 24

- hour and annual primary SO 2 standards and

established a new primary 1

- hour SO 2 standard at a level of 75 parts per billion (ppb) (75 FR

35520 ; June 22, 2010). As part of the 2010 revised primary SO 2 NAA QS (further referenced as

the revised SO 2 standard )

, U.S. EPA also modified how attainment is determined. The revised

SO 2 standard is attained when the three

- year average of the annual 99 th percentile 1

- hour daily

maximum concentrations does not exceed 75 ppb (75 FR 35520; June 22, 2010 ). U.S. EPA will

address the secondary SO 2 standard as part of a separate review.

Section 107(d) of the Clean Air Act (CAA) governs the process for a rea designations, and directs

states to submit their SO 2 designation recommendations to U.S. EPA by June 3, 2011.

Following the promulgation of a new or revised air quality standard, the Clean Air Act (CAA)

requires the Governor to recommend initial designations of the attainment status for all areas of

the St ate. Areas can be classified as nonattainment (does not meet, or contributes to a nearby

area that does not meet the NAAQS), attainment (meets the NAAQS), or unclassifiable (cannot

be classified based on available data). Illinois is, therefore, required to provide recommendations

for attainment/nonattainment area boundaries for the 2010 revised primary SO 2 standard. The

U.S. EPA will act on the St a te’s recommendations by both affirming and promulgating the

recommended designation boundaries, or by promul gating new designations. U.S. EPA stated in

its preamble to the 2010 NAAQS

, that i n addition to air monitoring data

, refined dispersion

modeling information may be used as part of an analy tical approach to designations. H owever

,

according to the U.S. EPA Ma rch 24, 2011 memorandum entitled, A rea D esignations for the6

2010 Revised Primary Sulfur Dioxide National Ambient Air Quality Standards

, the U.S EPA

does not believe it would be “realistic or appropriate to expect states to complete modeling for all

significant sources of SO 2 and assess the results in time for the June 2011 designation

recommendations”

. States would instead present modeling to address additional violations in

the course of developing State Implementation Plan (SIP) revisions und er Section 110(a) of the

Clean Air Act as a

, “basis for re

- designation of nonattainment and unclassifiable areas to

attainment” (75 FR at 35570)

. Illinois does not intend to submit dispersion modeling in support

of designation s at this time . Rather, IEPA will complete dispersion modeling in the course of

developing SIP revisions.



### Federal Guidance

The Illinois Environmental Protection Agency (IEPA) relied on guidance identified in a

memorandum issue d by U.S. EPA on March 24, 2011 which referenced pages in the pr eamble of

the lead NAAQS final rule regarding criteria for developing this recommendation and for

establishing the geographic boundaries of nonattainment areas (NAA) for the 2010 revised SO 2

standard. In this guidance, U.S. EPA recommend e d that s tates designate areas with air quality

data showing violations of the SO 2 NAAQS, and nearby areas that cause or contribute to

NAAQS violations, be designated nonattainment. Due to the localized nature of SO 2 impacts,

U.S. EPA also recommends that the “ c ounty line” associated with the violating monitor(s) serve

as the starting point

, or presumptive boundary , for new SO 2 nonattainment area s

. U.S. EPA

provides states with the ab ility to depart from county boundaries based on area

- specific analyses.

States may request non attainment area boundaries that are smaller than the existing violating

county boundaries where counties, or po rtions of counties

, do not contribute to non attainment

based on an examinat ion of five factors. States may also request nonattainment area boundaries

that are larger than the current cou nty to include adjacent counties when those cou nties contain

emission sources a nd other factors that may contribute to the non attainment problem

. This

report provides the basis for recommendations by the IEPA for attainment/nonattainment

designation boundaries for all areas in the State of I llinois for the revised SO 2 standard.7



### Five Factor Analysi s

The U.S. EPA recommends that s tates consider t he following five factors in assessing whether to

depart from county boundaries as the designated nonattainment area boundary:

1. Air Quality Data : an evaluation of the design value calculation s for each monitor in the

State. Th is calculation consists of the 3

- year average of the annual 99th percentil e daily

maximum 1

- hour SO 2 concentrations collected at each monitor

. A detailed discussio n of

air quality in Illinois is provided in the sections below.

2. Emissions

- R elated Data : an evaluation of SO 2 emissions from sources located in and

around the violating area which may potentially contribute to observed or modeled

violations of the NAAQS. The emissions data used in this analysis are based on actual

SO 2 emissions reported to the IEPA for 2007 through 2009

.

3. Meteorology : an evaluation of weather conditions, including wind speed and direction

that affect the plume of sources contributing to ambient and monitored SO 2

concentrations. Pollution roses are derived from I EPA sites in the proposed NAA areas,

and all sites use either collocated wind measurements, or the nearest IEPA monitoring

site with wind direction measurements, along with hourly SO 2 concentrations. The

pollution roses show the frequency of wind directio ns at the monitor when 1

- hour

concentrations of SO 2 that exceed the standard are occurring. Detailed meteor o logy used

in IEPA’s analysis is discussed in the following sections

.

4. Geography/Topography : Includes an evaluation of the physical features of t he land that

might have an effect on the airshed and, therefore, on the distribution of SO 2 at and near

the monitors . Due to the fact that n one of the recommended SO 2 nonattainment areas in

Illinois have any geographical or topographical barriers that sign ificantly limit air8

pollution transport w ithin the airsheds, the geography/topography factor did not play a

significant role in determini ng the nonattainment boundaries in Illinois

.

5. Jurisdictional Boundaries : Includes an analysis of areas that provide clear ly defined

legal boundaries including landmarks or geographic coordinates to carry out air quality

planning and enforcement functions for the nonattainment area. The Illinois EPA is

responsible for air quality regulatory programs for every county in the state.

Jurisdictional boundaries considered in this analysis are consistent with recommended

geographic boundaries, or “county line” definitions, outlined in U.S. EPA’s guidance

documentation. Sub

- county b oundaries in this study reflect 2009 Politica l Township

boundaries provided by Property Tax Division of the Illinois Department of Revenue

.



### Illinois Air Quality

As recommended by U.S. EPA, t he first step in identifying area s that are in violation of the

revised SO 2 NAAQS is to evaluate the most recent three years of ambient air monitoring

data . Table 1 shows the most recent three consecutive years of qual ity assured air monitoring

data for 2008 through 2010 , along with the resulting design values

. The design value is

defined as the 3

- y ear average of the annual 99th percentile daily maximum 1

- hour SO 2

concentrations collected at each monitor (which is generally the fourth highest daily

maxi mum 1

- hour concentration, averaged over three consecutive years)

. The general trend in

annual 1

- hou r 99 th percentile values statewide has been downward. Overall, 16 of the 19

Illinois SO 2 monitoring sites had 99 th percentile values in 2010 that were lower than those

same values in 2008. Despite the significant improvement in air quality statewide, fou r

monitoring sites cur

rently violate the revised SO 2 NAAQS . These four monitors are located

in Tazewell, La Salle, Cook

, and Madison c ounties (see Figure 1)

. The remaining fifteen

monitoring sites are attaining the revised SO 2 NAAQS , most by a considerable margin.9 

### Table 1

2008

- 2010 Illinois SO 2 

### Design Values (ppb)

AQ S

Code County Site Annual 99 th 

### Percentiles Design

Value 2008 2009 2010

170310050 Cook Chicago

- SE Police 35 19 21 25

170310063 Cook Chicago

- CTA 26 21 14 20

170310076 Cook Chicago

- Com Ed 26 24 20 23

170311601 Cook Lemont 97 114 90 100

170314002 Cook Cicero 43 29 31 34

170314201 Cook Northbrook 13 17 15 15

170990007 La Salle Oglesby 326 8 14 116

171150013 Macon Decatur 44 36 49 43

171170002 Macoupin Nilwood 20 16 15 17

171191010 Madison South Roxana 152 81 57 97

171193007 Madison Wood River WTP 67 46 54 56

171430024 Peoria Peoria 52 21 43 39

171570001 Randolph Houston 35 26 31 31

171630010 St. Clair East St. Louis 35 30 31 32

171670006 Sangamon Springfield 131 24 31 62

171790004 Tazewell Pekin 243 233 228 235

171850001 Wabash Mount Carmel 90 69 66 75

171851001 Wabash Rural Wabash Co. 57 53 59 56

171970013 Will Joliet 56 32 24 3710 

### Figure 111



### Illinois 5 Factor Analysis

The U.S. EPA recommends that states consider the following five factors in assessing whether to

depart from county boundaries as the designated nonattainment area boundary. As previously

mentioned, Illinois has four counties where monitored viol ations of the revised SO 2 NAAQS are

occurring. The information in the following sections provides boundary recommendations based

on the five factors outlined in U.S. EPA guidance within each violating county or adjacent

county.

Tazewell County

Air Quality

There are two SO 2 monitors in the Peoria area. The first monitor is located west of the Illinois

River in Peoria , while the second monitor is located east o f the Illinois River in Pekin (see Figure

2) . Monitoring data for both sites is listed bel ow in Table 2 . The 2008

- 2010 design value for the

Peoria monitor is below the revised 1

- hour NAAQS , while t he design value for the Pekin

mon itor is well above the revised 1

- hour NAAQS

. The 2008 through 2010 annual 99 th

percentiles show a small decrease at the Peoria site and consistently high values at the Pekin site.

Table 2

– Peoria Area Air Quality Data for 2008

- 2010 (ppb)

AQS Code County Site Annual 99 th Percentiles Design

Value 2008 2009 2010

171430024 Peoria Peoria 52 21 43 39

171790004 Tazewell Pekin 243 233 228 235

Emissions

Table 3 lists the major SO 2 emission sources ( reported SO 2 emissions over 100 tons per year for

at least one of the years from 2007 through 2009) with in both Tazewell and Peoria c ounties . The

locations of these sources are shown in Figure 2. From Figure 2, there are two sources in the

vicinity of the violating monitor in Pekin: Aventine Renewable Energy, and Midwest Generation

– Powerton. Overall, t here has been a small decrease in SO 2 emissions within the Peoria area12

during the period , h owever Aventine and Midwest Generation

- Powerton, have shown either

steady or increasing emissions trends during this period

.

Table 3

– Tazewell and Peoria County Reported SO 2 Emissions for 2007

- 200 9

County ID Number Facility Name Reported SO 2 Emissions

(Tons per Year)

2007 2008 2009

Tazewell 179060ACR Aventine Renewable Energy Inc 12239.93 11830.31 11819.57

Tazewell 179801AAA Midwest Generation

– Powerton 20543.67 22355.08 22125.00

Peoria 143065AJE Archer Daniels Midland Co 3140.00 3049.00 2587.00

Peoria 143805AAG Ameren

– Edwards 14535.90 11224.10 11734.40

Peoria 143808AAA Keystone Steel & Wire Co 109.26 137.53 86.61

Figure 2

– Location of Major SO 2 Emission Sources in Tazewell and Peoria Counties13

Meteorology

The closest National Weather Service ( NWS ) meteorological monitoring site to the Pekin area is

located at the Greater Peoria Airport. The IEPA considers the meteorological characteristics of

the airport site to generally be representative of the Tazewell County area, although it is possible

that some local

- scale differences may occur within the Illinois River valley, where Pekin is

located. Figure 3 shows the climatological wind rose , or wind frequency distrib ution, for the

Peoria A irport. The figure shows that southerly winds are most frequent in the Peoria area , with

a second ary maximum from the northwest.

Figure 3

- Greater Peoria Airport Climatological Wind R ose14

Figure 4 shows the pollution rose for t he Pekin monitor , which depicts the wind directions

associated with measured SO 2 concentrations exceeding 75 ppb at this location. Comparing the

pollution rose in Figure 4 to Figure 5, which shows the locations of major SO 2 emission sources

with respect t o the Pekin monitor, it is apparent that the wind direction during exceedance hours

is either from the west or west

- southwest, which aligns the nearby Aventine facility , and, to a

lesser extent, Midwest Generation

– Powerton with the monitor location

.

Figure 4

– Pekin Pollution R ose15 Figure 5

- Aerial Photo of the Pekin M onitor and n earby F acilities

Since the Pekin monitor is at a slightly higher elevation than the two facilities to the west

southwest, IEPA believes that the high concentrations that are occurring at this monitor are

primarily due to emissions from these l ocal sources.

Jurisdictional Boundaries

The Illinois EPA is responsible for air quality regulatory programs for every county in the state.

Jurisdictional boundaries considered in this analysis are consistent with recommended geographic

boundaries, or “presumptive boundary” definitions, outlined in U.S. EPA’s guidance documentation.

Boundaries in this study reflect the 2009 political township boundaries provided by the Property Tax

Division of the Illinois Department of Revenue. Based on the geo graphic location of Pekin and the

individual sources , it is expected that the coordination of planning activities required to address the

nonattainment designation can be carried out in a cohesive manner.16

Recommendation

Based on the factors discussed above, Illinois recommends that Pekin and Cincinnati Townships

in Tazewell County be designated as nonattainment for the 2010 1

- hour SO 2 NAAQS (see Figure

6) . These two townships contain both the violating monitor and the tw o most culpable emission

sources

.

Figu re 6

– Proposed SO 2 Nonattainment Area Boundary for Tazewell County17

La Salle County

Air Quality

There is one SO 2 monitor in La Salle County located in Oglesby. Monitoring data for this site is

listed below in Table 4. The 2008

- 2010 design value for the Oglesby monitor currently exceeds

the revised 1

- hour NAAQS

. However, t he 2008 through 2010 annual 99 th perce ntiles show a

la rge decline in SO 2 values measured at the Oglesby site related to the suspension of operations

at the Lone Star Industries cement plant in 2008. The 99 th percentiles for both 2009 and 2010

were the lowest values in the state and the Oglesby monitor is exp ected to attain the revised 1

-

hour NAAQS by the end of 2011.

Table 4

– La Salle County Air Quality Data for 2008

- 2010 (ppb)

AQS Code County Site Annual 99 th Percentiles Design

Value 2008 2009 2010

170990007 La Salle Oglesby 326 8 14 116

Emissions

Table 5 lists the major SO 2 emission sources (reported SO 2 emissions over 100 tons per year for

at least one of the years from 2007 through 2009) in La Salle County. The locations of these

sources are shown in Figure 7. From Figure 7, there is only one source in the vicinity of t he

violating monitor in Oglesby: Lone Star Industries. This facility has been closed since 2008,

which is reflected in the large d ecrease in SO 2 e missions shown in Table 5

. T here has also been

a significant reduction in SO 2 emissions at the Illinois Cement Company plant in La Salle

,

a lthough this facility remains operational.

Table 5

– La Salle County Reported SO 2 Emissions for 2007

- 2009

County ID Number Facility Name Reported SO 2 Emissions

(Tons per Year)

2007 2008 2009

La Salle 099030AAZ Illinois Cement Co 167.8 160.34 90.17

La Salle 099490AAD Owens

- Brockway Glass Container Inc 228.24 221.72 208.69

La Salle 099816AAF Lone Star Industries Inc 2937.16 2241.18 0 .00

La Salle 099825AAG Pilkington North America Inc 293.66 255.1 308.2218 Figure 7

– Location of Major SO 2 Emission Sources in La Salle County

Meteorology

The Oglesby monitor is in north

- central Illinois, roughly the same distance from NWS stations at

the Rockford A irport and at t he Peoria A irport. Figure 8 shows the climatological wind rose for

the Rockfor d airport. The Rockford wind rose looks very similar to the Peoria wind rose

,

presented previously in Figure 3

. There is a pronounced maximum frequency of southerly winds

at Rockford , as at Peoria , with a secondary maximum from the northwest. The IEPA co nsiders

these NWS stations to generally be representative of conditions occurring in La Salle County,

although it is recognized that the Vermillion River valley, where the Lone Star facility is located,

may cause localized meteorological influences.19 Figur e 8

- Greater Rockford Airport Climatological Wind R ose

Figure 9 shows the pollution rose for the Oglesby monitor, while Figure 10 is an aerial photo that

shows the relationship of the one large source to the monitor. The pollution rose shows that the

wind direction during exceedance hours is primarily from the southwest, which corresponds well

with the location of Lone Star Industrie s , which is located to the south and southwest of the

monitor

. Based on this analysis, the IEPA concludes th at exceedances of the revised 1

- hour SO 2

NAAQS at Oglesby are due primarily to emissions from the Lone Star facility.20 Figure 9

– Oglesby Polluti on Rose

Figure 10

- Aerial photo of the Oglesby Monitor and n earby F acility21

Jurisdictional Boundaries

The Illinois EPA is responsible for air quality regulatory programs for every county in the state.

Jurisdictional boundaries considered in this analysis are consistent with recommended geographic

boundaries, or “presumptive boundary” definitions, outlined in U.S. EPA’s guidance documentation.

Boundaries in this study reflect the 2009 political township boundaries provided by the Property Tax

Division of the Illinois Department of Revenue. Based on the geographic location of Oglesby and

the individual sourc es, it is expected that the coordination of planning activities required to address

the nonattainment designation can be carried out in a cohesive manner.

Recommendation

Based on the factors discussed above, Illinois recommends that La Salle Township in La Salle

County be designated as nonattainment for the 2010 1

- hour SO 2 NAAQS (see Figure 11). This

township contains both the violating monitor and the most culpable source of SO 2 emissions

.

Figure 11

– Proposed SO 2 Nonattainment Area Boundary for La Sal le County22

Cook and Will Count ies

Air Quality

There are seven SO 2 monitor s located in Cook and Will Counties. Monitoring data for these

site s are listed below in Table 6 . The 2008

- 2010 design value s for all of the sites are well below

the revised 1

- hour NAAQS , except for the monitor at Lemont

. As can been in Figure 12, the

distribution of design values across northeastern Illinois indicates that the Lemont monitor

represents a “hot spot” due to impacts from local emission sources.

Table 6

– Cook and Will County Air Quality Data for 2008

- 2010 (ppb)

AQS Code County Site Annual 99 th Percentiles Design

Value 2008 2009 2010

170310050 Cook Chicago

- SE Police 35 19 21 25

170310063 Cook Chicago

– CTA 26 21 14 20

170310076 Cook Chicago

- Com Ed 26 24 20 23

170311601 Cook Lemont 97 114 90 100

170314002 Cook Cicero 43 29 31 34

170314201 Cook Northbrook 13 17 15 15

171970013 Will Joliet 56 32 24 37

Emissions

Table 7 lists the major SO 2 emission sources (reported SO 2 emissions over 100 tons per year for

at least one of the years from 2007 through 2009) within Cook and Will counties. The locations

of these sources are shown in Figure 1 2. From Figure 1 2, there are three sources in the vicinity

of the violating monitor in Lemont : Oxbow Midwest Calcining, CITGO Petroleum, and Midwest

Generation

– Will County

. It should be noted that all three nearby sources are located in Will

County, although the Lemont monitor is locate d in Cook County. Overall, SO 2 emissions in

Cook and Will counties have dropped by almost 50% since 2007, with the most significant

reductions occurring at the two oil refineries (CITGO and Exxon Mobil)

.23 Table 7

– Cook and Will County Reported SO 2 E missions for 2007

- 2009

County ID Number Facility Name Reported SO 2 Emissions

(Tons per Year)

2007 2008 2009

Cook 031012ABI Corn Products International Inc 1942.00 2203.00 991.00

Cook 031069AAI Saint

- Gobain Containers Inc 354.05 344.84 300.30

Cook 031123ABP Congress Development Co 57.43 81.33 204.00

Cook 031300AAJ Koppers Inc 846.80 823.17 705.38

Cook 031600ADY Carmeuse Lime Inc 359.57 321.46 0.00

Cook 031600AIN Midwest Generation

- Crawford 8881.90 6626.90 7107.50

Cook 031600AMI Midwest Generation

- Fisk 4954.51 4485.561 4217.56

Cook 031600CTF Saints Mary and Elizabeth Med. Center 0.07 0.10 125.01

Will 197090AAI CITGO Petroleum Corp 14170.75 6135.86 336.62

Will 197800AAA Exxon Mobil Oil Corp 22095.05 16404.03 1914.79

Will 197803AAK Oxbow Midwest Calcining LLC 7153.21 6204.85 4990.62

Will 197809AAO Midwest Generation

– Joliet 20265.72 18281.72 17996.87

Will 197810AAK Midwest Generation

- Will County 17310.81 16496.78 12602.53

Figure 12

– Location of Major SO 2 Emission Sources in Cook and Will Counties24

Meteorology

The Lemont mo nitor is located in Cook County , so the nearest NWS site is at Chicago’s O’Hare

A irport. Since the Lemont site is a similar distance from Lake Michigan as O’Hare airport, the

effect of L ake Michigan on local wind direction s should be comparable

. Figure 13 shows the

climatological wind rose for O’Hare A irport. Unlike the Peoria and Rockford wind roses shown

previously , a higher frequency of wind directions occur at O’Hare from south erly thro ugh

west erly , with a secondary maximum from the northeast.

Figure 13

– Chicago

- O’Hare Airport Climatological Wind Rose25

Figure 14 shows the pollution rose for th e Lemont monitor, while Figure 15 is an aerial photo

that shows the spatial relationship of major emission sources to the monitor. The pollution rose

shows that the wind direction during exceedance hours is mostly from the west, which indicates

likely contributions from Oxbow Midwest Cal cining, and, to a lesser extent, CITGO Petroleum

.

With the close proximity of major sources upwind from the monitor on high concentration days,

IEPA believes that nonattainment at the Lemont monitor is primarily due to these local sources.

Figure 14

- Lemont Pollution Rose26 Figure 15

- Aerial photo of the Lemont monitor a nd nearby F acilities

Jurisdictional Boundaries

The Illinois EPA is responsible for air quality regulatory programs for every county in the state.

Jurisdictional boundaries co nsidered in this analysis are consistent with recommended geographic

boundaries, or “presumptive boundary” definitions, outlined in U.S. EPA’s guidance documentation.

Boundaries in this study reflect the 2009 political township boundaries provided by the P roperty Tax

Division of the Illinois Department of Revenue. Based on the geographic location of Lemont and the

individual sources, it is expected that the coordination of planning activities required to address the

nonattainment designation can be carried out in a cohesive manner.

Recommendation

Based on the factors discussed above, I llinois recommends that Lemont Township in Cook

County and Du Page and Lockport Townships in Will County be designated as nonattainment for

the 2010 1

- hour SO 2 NAAQS (see Figure 16 ). The s e three towns hips contain both the violating27

monitor and the most culpable source s of SO 2 emissions impacting the Lemont monitor

.

Figure 16

– Proposed SO 2 Nonattainment Area Boundary for Cook an d Will Counties

Madison County

Air Quality

There are three SO 2 monitors in the Metro

- East area. Two of the monitors are located in western

Madison County, while the third monitor is located in East St. Louis in St. Clair County.

Monitoring data for all three sites is listed in Table 8 . The 2008

- 2010 design value s for the

Wood River and East St. Louis monitor s are well below the revised 1

- hour NAAQS , whil e the

design value for the South Roxana monitor exceeds the revised 1

- hour NAAQS . The 2008

through 2010 annual 99 t h percentiles decreased at all three sites, with the most significant

improvement occurring at the Sou th Roxana monitor.28 Table 8

– Metro

- East Area Air Quality Data for 2008

- 2010 (ppb)

AQS Code County Site Annual 99 th Percentiles Design

Value 2008 2009 2010

171191010 Madison South Roxana 152 81 57 97

171193007 Madison Wood River WTP 67 46 54 56

171630010 St. Clair East St. Louis 35 30 31 32

Emissions

Table 9 lists the major SO 2 emission sources (reported SO 2 emissions over 100 tons per year for

at least one of the years from 2007 through 2009) in Madison County . The locations of these

sources are shown in Figure 17 . From Figure 17 , there is only one source in proximity to the

violating monitor in South Roxa na : ConocoPhillips

. SO 2 emiss ions in Madison County have

decreased significantly during the 2007

- 2009 period . The largest reductions occurred at the

ConocoPhillips oil refinery , which is located near the South Roxana monitor

, and US Steel’s

Granite City Works.

Table 9

– Madison County Reported SO 2 Emissions for 2007

- 2009

County ID Number Facility Name Reported SO 2 Emissions

(Tons per Year)

2007 2008 2009

Madison 119010AAE Alton Steel Inc 121.43 142.88 63.25

Madison 119020AAE Dynegy Midwest Gen.

– Wood River 6462.30 6873.20 9089.10

Madison 119040ATN Gateway Energy & Coke Co LLC 0.00 0.00 580.34

Madison 119090AAA ConocoPhillips Co 13629.96 12273.72 5761.00

Madison 119813AAI US Steel

- Granite City 6187.15 5612.67 1428.3129

Figure 17

– Location of Major SO 2 Emission Sources in Madison County

Meteorology

T he nearest NWS site to Madison County is Lamb ert Field in St. Louis. Figure 18 shows the

climatological wind rose for Lambert Field. Unlike the wind roses previously shown, the most

frequent wind directions are from the south through southeast, with a strong secondary maximum

from the northwest

. The IEPA considers the meteorological conditions at Lambert Field to

generally be representative of co nditions occurring in Madison County, although it is recognized

that the South Roxana monitor is located on the flood plain of the Mississippi River and may

experience some localized differences.30 Figure 18

- St. Louis

- Lambert Field Climatological Wind R ose

Figure 19 shows the pollution rose for the Sout h Roxana monitor, while Figure 20 is an aerial

photo that shows the relat ionship of the one large source to the monitor. The pollution rose

shows that the wind direction during exceedance hours is primarily from the northwest which

aligns the nearby Conoco Phillips refinery with the monitor location

. With the proximity of this

major nearby source to the moni tor, IEPA concludes that emissions from this facility are

primarily responsible for exceedances of the revised 1

- hour SO 2 NAAQS at South Roxana.31 Figure 19

- South Roxana Pollution Rose

Figure 20

- Ae rial photo of t he South Roxana Monitor and nearby F acility32

Jurisdictional Boundaries

The Illinois EPA is responsible for air quality regulatory programs for every county in the state.

Jurisdictional boundaries considered in this analysis are consistent with recommended geographic

boundaries, or “presumptive boundary” definitions, outlined in U.S. EPA’s guidance documentation.

Boundaries in this study reflect the 2009 political township boundaries provided by the Property Tax

Division of the Illinois Department of Revenue. Based on the geographic location of Roxana and the

individual source s, it is expected that the coordination of planning activities required to address the

nonattainment designation can be carried out in a cohesive manner.

Recommendation

Based on the factors discussed above, Illinois recommends that Chouteau and Wood River

Townships in Madison County be designated as nonattainment for the 2010 1

- hour SO 2 NAAQS

(see Figure 21). These two townships contain both the violating monit or and the most culpable

source of SO 2 emissio ns impacting the South Roxana monitor

.

Figur e 21

– Proposed SO 2 Nonattainment Area Boundary for Madison County33



### R ecommendations

IEPA’s recommendations for attainment/nonattainment boundary designations in Illinois for the

2010 revise d 1

- h our SO 2 nation al ambient air quality standard are contained in Table 10

.

Current air quality data collected by the I EPA indicates that the 2010 revised primary SO 2

NAAQS is not being met in the areas listed in Table 10, and that they should be designat ed as

nonattainment areas. The locations of IEP A’s recommended SO 2 nonattainment areas for the

State of Illinois are shown in Figure 22.

The Clean Air Act does not specify the geographic boundaries, size, or the extent to which

source contributions would require that an area be desi gnated as nonatta inment for the 2010

revised primary SO 2 standard

, nor has U.S. EPA promulgated rules prescribing such. IEPA’s

recommendations are consistent with the guidance memorandum provided by U.S. EPA and are

based on an eval uation of current air qualit y, the locat ion and magnitude of SO 2 emission

sources , and other factors. The IEPA recognizes that each of the factors considered in this

evaluation

, when evaluated individually, are not necessarily conclusive. Rather, IEPA’s

recommendations are based on consideration of all of the factors taken together. I t is expected

that the coordination of planning activities required to address the nonattainment designations

can be carried out in a cohesive ma nner. T he data sources utilized in the preparation of t his

report are summarized in Table 11

.34 

### Figure 2235 

### Table 10

Recommended Attainment/Nonattainment Designations in Illinois f or the 2010

Revised Primary 1

- hour 

## SO 2 

### National Ambient Air Quality Standard

County (Part ial ) Designation Name of Area

Tazewell County :

Pekin and Cincinnati Townships

Aux Sable Township

Goose Lake Township

All Other Townships Nonattainment Tazewell County

Remainder of Tazewell County Unclassifiable

La Salle County :

La Salle Township Nonattainment La Salle County

Remainder of La Salle County Unclassifiable

Cook County :

Lemont Township Nonattainment Cook County

Remainder of Cook County Unclassifiable

Will County :

Lockport and DuPage Townships Nonattainment Will County

Remainder of Will County Unclassifiable

Madison County :

Chouteau and Wood River Townships Nonattainment Madison County

Remainder of Madison County Unclassifiable

All Other Counties Unclassifiable Illinois36 

### Table 11

SO 2 

### NAA Five Factor Documentation

Factor Data Analysis Data Source Date of Study

1. Air Quality SO 2 2008

- 2010 Design Values

at individual monitors

(statewide) IEPA BOA Database,

Air Monitoring

Section 2008

- 2010

2. Emissions Emission inventory information

for SO 2 IEPA 2007

- 2009

Reported Emissions, 2009

3. Geography/Topography Statewide elevations Google Maps Data 2008

4. Jurisdictional Boundaries Illinois Department of

Revenue, Political Townships Illinois Department of

Revenue, Property

Tax Division,

Springfield, Illinois 2009

5. Meteorology Weather patterns

– Wind Roses

and Pollution Roses.

1961

– 1990 National Weather

Service, Illinois State

Climatologist Office October 7, 2004